International

  • August 20, 2024

    IRS Tax-Exempt Compliance Unit Work Too Slow, TIGTA Says

    A decision to expand the scope of checks made by the Internal Revenue Service's Tax-Exempt Compliance Unit resulted in cases taking three times as long to close and a decrease in taxpayers reached by more than half, the Treasury Inspector General for Tax Administration said Tuesday.

  • August 20, 2024

    Allen Matkins Tax Group Leader Jumps To Covington In LA

    Covington & Burling LLP has added to its Los Angeles office a partner with more than 20 years of experience who most recently led Allen Matkins Leck Gamble Mallory & Natsis LLP's tax group, describing the new hire as "one of the country's leading authorities on partnership tax."

  • August 20, 2024

    Trade Group Urges Consistency In Pillar 2 Reporting Standard

    The Organization for Economic Cooperation and Development should focus on making sure there is a standardized approach to acquiring the cross-jurisdiction information required for Pillar Two global minimum tax returns while also minimizing the compliance burden, the National Foreign Trade Council said Tuesday.

  • August 20, 2024

    A Deep Dive Into Law360 Pulse's 2024 Women In Law Report

    The legal industry continues to see incremental gains for female lawyers in private practice in the U.S., according to a Law360 Pulse analysis, with women now representing 40.6% of all attorneys and 51% of all associates.

  • August 20, 2024

    These Firms Have The Most Women In Equity Partnerships

    The legal industry still has a long way to go before it can achieve gender parity at its upper levels. But these law firms are performing better than others in breaking the proverbial glass ceiling that prevents women from attaining leadership roles.

  • August 20, 2024

    Aussie Capital Gains Tax Edit May Hit Green Energy, Pros Say

    An Australian proposal to generally broaden the scope of the country's foreign resident capital gains tax regime could end up restricting foreign investment in the renewable energy sector, a group representing accounting professionals in the country said Tuesday.

  • August 20, 2024

    IRS Proposes Update To Qualified Domestic Trust Regs

    The Internal Revenue Service proposed regulations Tuesday that would update federal estate tax rules for estates of decedents passing property to or for the benefit of a noncitizen spouse in a domestic trust in cases where the executor has made an election to be a qualified domestic trust.

  • August 20, 2024

    EU Tweaks Anti-Subsidy Duties On Chinese EVs

    The European Commission said Tuesday that it is adjusting the anti-subsidy duties that it will charge Chinese exporters of electric vehicles, a move that it had provisionally announced at the beginning of July.

  • August 19, 2024

    Eaton Ordered To Give Int'l Employee Records To IRS

    Eaton Corp. must disclose employment records for some European workers in its transfer pricing dispute with the U.S. government because public interest in curtailing tax avoidance outweighs the interest in protecting the workers' privacy, an Ohio federal judge ruled Monday.

  • August 19, 2024

    Danish Gov't Wants Evidence Excluded In $2B Tax Fraud Case

    A New York federal court should exclude some evidence presented by U.S. pension plans accused in what the Danish tax agency is calling a $2.1 billion tax fraud scheme, the agency said.

  • August 19, 2024

    Chile Senate Panel OKs Bank Secrecy, Whistleblower Plans

    Chile's Senate Finance Committee approved changes to a larger tax compliance bill's proposals for lifting the country's bank secrecy laws in certain situations and for creating an anonymous whistleblower process for reporting tax crimes.

  • August 19, 2024

    Treasury Floats Timing Shift For Foreign Currency Accounting

    The U.S. Treasury Department proposed regulations Monday that would adjust the timing for when companies could opt to use the so-called mark-to-market accounting method for gains or losses that arise from foreign currency transactions.

  • August 19, 2024

    Swedish Advisory Body Considering Pillar 2 Updates

    A Swedish advisory council is considering a proposal that would add administrative and other clarifications to the country's implementation of the Organization for Economic Cooperation and Development's global minimum tax on large multinational corporations.

  • August 16, 2024

    Kyocera Says It Doesn't Need Records For R&D Credits

    Multinational electronics maker Kyocera said Friday that it wasn't required to keep any specific paperwork to back up its claim to research tax credits, contrary to the U.S. government's claims, according to a filing in South Carolina federal court.

  • August 16, 2024

    UK Dependency Considering Global Minimum Tax Bills

    Jersey is considering draft legislation that would implement the Organization for Economic Cooperation and Development's 15% minimum tax on multinational entities making over €750 million ($828 million) annually, in line with a declaration from it and other U.K. crown dependencies to do so starting next year.

  • August 16, 2024

    Democratic Gov't Control Could Bolster US' Pillar 2 Plans

    Vice President Kamala Harris and congressional Democrats would likely double down on plans to align the U.S. tax code with the global minimum tax designed by the Organization for Economic Cooperation and Development if they win total control of the federal government in the November elections.

  • August 16, 2024

    UN Votes For Global Services As First Priority Under Tax Pact

    The United Nations voted Friday to make taxation of cross-border services the most prioritized topic for a legally binding agreement to be finalized by late 2027 alongside the organization's framework convention on international tax cooperation.

  • August 16, 2024

    IRS To Let Private Cos. Into Real-Time Biz Audit Program

    The Internal Revenue Service is opening its compliance assurance process real-time audit program to privately held C corporations, including foreign-owned ones, for 2025, the agency announced.

  • August 16, 2024

    Taxation With Representation: Cleary, Kirkland, Skadden

    In this week's Taxation with Representation, Mars Inc. sets a 2024 record with its $36 billion acquisition of Kellanova, Carlyle inks a $3.8 billion purchase with Baxter International Inc., and Performance Food Group Co. agrees to a $2.1 billion cash deal with Cheney Bros. Inc.

  • August 15, 2024

    Doctor Wants Contempt Fine Dropped In Foreign Asset Case

    A doctor who incurred $1.1 million in liabilities for failing to report his foreign bank accounts is asking a Michigan federal court to waive his $20,000 civil contempt fine because the court restricted his only financial assets to paying the liabilities.

  • August 15, 2024

    Tax Pros Navigate Chaos, Rewards In Climate Law's 2nd Year

    Energy tax attorneys have been knee-deep in project finance deals for the past year since the Inflation Reduction Act of 2022 triggered a flurry of clean energy investments, but the work, they say, has been fulfilling as part of broader efforts to save the environment.

  • August 15, 2024

    Taxes Could Be Key To Cutting Crypto Emissions, IMF Says

    The growing environmental impact of crypto-asset mining and related data centers could be mitigated with tax measures aimed directly at such facilities, the International Monetary Fund said Thursday.

  • August 15, 2024

    Germany Seeks Input On Tightened Transfer Pricing Rules

    Germany is poised to make multinational corporations responsible for showing the economic necessity of intra-group, cross-border debt relationships when they deduct expenses for financing with borrowed capital, according to a consultation by the federal government.

  • August 15, 2024

    Finland To Have EU's 2nd-Highest VAT Rate Starting Sept. 1

    Finland's general value-added tax rate will jump to 25.5% from 24% starting Sept. 1, the country's tax agency said Thursday, putting it behind only Hungary for the highest VAT rate in the European Union.

  • August 15, 2024

    Aussie Senate Economics Committee OKs 15% Min. Tax Bill

    The Australian Senate's Economics Legislation Committee said it supports the passage of a three-bill package that would implement the OECD's 15% global corporate minimum tax on large multinational entities, sending it to the entire Senate for approval.

Expert Analysis

  • A Vision For Economic Clerkships In The Legal System

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    As courts handle increasingly complex damages analyses involving vast amounts of data, an economic clerkship program — integrating early-career economists into the judicial system — could improve legal outcomes and provide essential training to clerks, say Mona Birjandi at Data for Decisions and Matt Farber at Secretariat.

  • A Look At New IRS Rules For Domestically Controlled REITs

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    The Internal Revenue Services' finalized Treasury Regulations addressing whether real estate investment trusts qualify as domestically controlled adopt the basic structure of previous proposals, but certain new and modified rules may mitigate the regulations' impact, say attorneys at Simpson Thacher.

  • E-Discovery Quarterly: Recent Rulings On Text Message Data

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    Electronically stored information on cellphones, and in particular text messages, can present unique litigation challenges, and recent court decisions demonstrate that counsel must carefully balance what data should be preserved, collected, reviewed and produced, say attorneys at Sidley.

  • Don't Use The Same Template For Every Client Alert

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    As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.

  • Think Like A Lawyer: Follow The Iron Rule Of Trial Logic

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    Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.

  • The Art Of Asking: Leveraging Your Contacts For Referrals

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    Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.

  • Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks

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    Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.

  • Deciding What Comes At The End Of WTO's Digital Tariff Ban

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    Companies that feel empowered by the World Trade Organization’s recent two-year extension of the ban on e-commerce tariffs should pay attention to current negotiations over what comes after the moratorium expires, as these agreements will define standards in international e-commerce for years to come, say Jan Walter, Hannes Sigurgeirsson and Kulsum Gulamhusein at Akin Gump.

  • 4 Ways To Refresh Your Law Firm's Marketing Strategy

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    With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.

  • This Earth Day, Consider How Your Firm Can Go Greener

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    As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.

  • Cum-Ex Prosecutions Storm Shows No Sign Of Abating

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    The ongoing trial of Sanjay Shah in Denmark is a clear indicator that efforts remain focused on holding to account the alleged architects and beneficiaries of cum-ex trading, and with these prosecutions making their way across Europe, it is a more turbulent time now than ever, says Niall Hearty at Rahman Ravelli.

  • Practicing Law With Parkinson's Disease

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    This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.

  • Why Supreme Court Should Allow Repatriation Tax To Stand

    If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.

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